Institute of Certified Bookkeepers
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Acting as Registered BAS Agent

  • Member in Practice
  • Practice Certificate
  • 5 posts
  • # 117396

Hello All – Hope you are enjoying a well-deserved break over the festive period.


I’ve been approached by a financial services company (XYZ) to act as their Registered BAS Agent for bookkeeping services they provide & am hoping to get some advice on this.  With targeted marketing, they are expecting substantial growth in their client base over the next 6 months.  Having never acted as the BAS Agent on behalf of a 3rd party before - I’ve only ever been the bookkeeper/BAS Agent to a client directly - I want to be sure that I can implement this effectively & (most importantly) compliantly.


I have had an initial meeting with XYZ at which they have advised they charge the client a (very low) monthly bookkeeping fee.  They need a registered BAS Agent to lodge monthly/quarterly BASs. 

I explained I would need to review the work & they have said they would send me through the “working papers” each time.  I advised them of my fee (which is a flat hourly rate) & they are proposing that I bill the client directly each time.  However I don’t think a client would be happy if they are already paying a monthly bookkeeping fee to XYZ, to then be charged additionally for what they would simply see as “Lodgement”.   XYZ stated that it would “only take 5 minutes or so” to review, to which I explained that would depend on there not being any issues with the bookkeeping, so their perception of this concerns me a little.


I think I will need to have a second meeting with XYZ to review some of their actual bookkeeping as none of the individuals doing the work are bookkeepers or even Australian-qualified.    I feel it would be more appropriate for me to charge XYZ as it is their work I would be overseeing, rather than the client’s? 

I don’t know if this should be a fixed fee rather than hourly & in that case, how best to determine it?


In their written points for consideration that they’ve sent through to me, XYZ are also proposing charging me a 20% “Referral Fee” per lodgement (They made no mention of this at our face-to-face meeting!  Their actual words were that they “ ... wouldn’t be taking any commission on what I charge ...” but this suggests otherwise !?)


Are there any other ICB members who are acting in this capacity?

Do ICB have any guidelines or any member resources for this?  (I’ve found info on working under a BAS Agent but not the other way around)

I've just recently renewed my PI & PL insurance but am thinking I may also have to consider increasing my coverage if I take on this arrangement ? 

Any advice/guidance would be much appreciated.


Edited at 22 Dec 2018 06:26 AM GMT

Edited at 24 Dec 2018 02:31 AM GMT

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